North America
May 2017 Keeping ahead of global anti‐corruption trends is critical in today’s business markets. The Dorsey Anti‐Corruption Digest, which puts global trends at your fingertips, helps put you ahead. The deep experience of the Dorsey Anti‐Corruption team, drawn from the DOJ, the SEC and years in private practice, will keep you ahead. NORTH AMERICA THE UNITED STATES causing any violations of Sections 13(b)(2)(A) and 13(b)(2)(B) of the Exchange Act. Mondelez Mondelez Settles FCPA Charges agreed to pay a civil penalty of $13 million to the SEC. On January 9, 2017, Mondelez‐International, Inc. In a January 2017 administrative order, the SEC (“Mondelez”) settled with the U.S. Securities and found that Cadbury India had violated the Exchange Commission (“SEC”) to the tune of $13 internal controls and books‐and‐records million over allegations of illegal payments made provisions of the FCPA. In an effort to expand its by Mondelez’s Cadbury unit in India in violation production in India, Cadbury had sought of the FCPA. In the Matter of Cadbury Limited, assistance from an agent in securing the Adm. Proc. File No. 3‐17759 (Jan. 6, 2017). necessary licenses and approvals for a facilities Specifically, Mondelez consented to an entry of a expansion in Baddi, Himachal Pradesh, India. cease‐and‐desist order from committing or Cadbury India paid the agent’s invoices, totaling 1 over $200,000, for the preparation of of Sections 13(b)(2)(A), 13(b)(2)(B) and 30A of the applications and files related to the licenses for Exchange Act.
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